GRIC TIP Revisions in response to the 3hour conference call 

with EPA on 8-23-05 

On 8-29-05 Janet, Daniel and Michelle conducted a conference call to discuss TIP 

changes that needed to be made in response to the EPA Conference call. In addition, 

Daniel is researchng additional support documentation. Please find following a 

summary of the changes. If anyone has any other changes please let me or Michelle 

know. 

Part II Permit Requirements 

EPA Comment #15: Michelle will add overall language to state that we are incorporating 

Part 70 as of the Re-notice date for the TIP. She will add place holders for the unknown 

date. It is felt that it is easier to insert this language in one place rather than listing it in 

each area where Part 70 is mentioned. 

EPA Comment #17: Michelle will delete the first "Title V Permit" in the last sentence of 

3.9 of Part 11. 

EPA Comment (No#): Michelle will add the language submitted by EPA for sections 

7.2 and 8.0 (Part 11) referencing the "Administrator" and Director of GRIC DEQ. This 

section will indicate that the "Administrator" will mean "Dirctor" once EPA delegates the 

NESHAPs programs. 

MOA Agreement: 

MOA is only required for NESHAPs. Part 70, NSPS and TIP are delegated through 

program approval. 

Part 70 delegation requires a more complete description of eligibility (in addition to TAS 

eligibility statement) to address the elements of 70.4 (e.g., Permit Application forms) 

MOA needs to clarifl that "Administrator" means Director of GRIC in 7.2 & 8.0 only 

after the programs are approved. 

Open Burning: 

Do we need to make open burning federally enforceable or do we keep it local? 

Michelle will add a requirement to bum only dry materials in section 4.1 (A). 

Michelle will add a definition of "Smaller Piles" (e.g., 4ft x4ft) 

Michelle will add a definition of high winds that will apply to commercial bums only 

(e.g., 10 mph) 
Question for Pat Were we going to delete any reference to a burn prohibition in section 

3.1 (last sentence) and delete housing development area? I believe the decision to delete 

the reference to ban burning in housing developments came after the TIP went out for 

public comment. 

Aerospace Ordinance: 

Michelle will add testing requirements to include EPA Method 24 (VOC Content of 

Coatings), Method 25 and submethods and Method 18 (VOC content of gaseous 

emissions entering and exiting ECS), EPA method 204 A-F (capture and control) and a 

formula for calculating Total VOC vapor pressure. 

Fugitive Dust Ordinance: 

Comment #29 

Michelle was going to originally hold off on making changes to the fugitive dust 

ordinance but after much thought there would probably be an approvability problem if 

the changes were not made. So, unless anyone will have a high degree of heart burn over 

adding the silt loading requirements and test methods for unpaved roads and unpaved 

parking lots we should probably add these requirements. Any thoughts? 

Comment #3 1 

Roger recommended adding "trips" to section 4.0 to read "20 vehicle trips /day" 

Michelle will make this revision. 

Comment #33 

Michelle will add "in accordance with the appropriate test method in section 12.0. 

Michelle will also move the current section 12 to 13 and add the test methods from 

Maricopa County Rule 3 10 and appendix C to the new section 12. 

Comment #3 5 

Dan reviewed Maricopa County Rule 3 10 (table 9) and the blasting requirements include 

"discontinue blasting in winds > 25mph and pre-water and stabilizearea where vehicle 

traffic occurs. Michelle will add table 9 from Maricopa county Rule 3 10. 

Comment #37,38,39: 

Michelle and Dan will work together to add the necessary test methods to section 12.0 

from Maricopa County Rule 3 10 and appendix C. Maricopa County Appendix C is 22 

pages long and explains how to conduct each test method including the infamous ball 

drop method. Do we need to include appendix C if we add these test methods? I have 

mixed feelings about adding these test methods and thought that Tribes could sever 

things that didn't make since to implement. I don't know if EPA is considering these test 

methods as meeting RACT or RACMS. It is my understanding that Maricopa County 

Rule 3 10 is the equivalent of BACT or BACMs. They are implementing these 

requirements to meet the SIP. 
Comment #40: 

Michelle will revise the current definition in Part I1 and the ordinance of "owner andlor 

operator" to reflect the definition in Maricopa County Rule 3 10, section 220. 

Degreasing & Solvent Metal Cleaning 

Comment #44 

EPA recommended specific requirements be added for O&M Plans. EPA sent 

recommended language to add but it does not address Comment #44. The language 

provided by EPA is more vague than the language originally in the ordinance. I 

recommend leaving the ordinance unchanged so we have flexability to fit O&M plans to 

specific types of control equipment. If we change the O&M requirements in this 

ordinance we will have to change several of the ordinances. 

Comment #45 

We have not received any guidance concerning Initial Compliance Certification. Again, I 

recommend leaving the ordinances unchanged. If we change this ordinance we will have 

to change several of the ordnances. 

Secondary Aluminum Ordinance 

Comment #46 

Mchelle will add "the requirements in this ordinance are in addition to the federal 

MACT standards @ 40CFR7 Part 63, Subpart RRR." 

Comment #54 (Visible Emissions) 

Michelle will add a statement "as determined by applying EPA Method 9 protocol."